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    <description>Prior-period expenditure may be allowable where the liability crystallises during the relevant year, as discussed with reference to earlier decisions concerning such claims. The notes state that special leave petitions on this issue were dismissed on the basis that the matter was no longer open to question. They also address penalty under Section 271(1)(c), stating that penalty proceedings linked to deleted additions were consequential and that the related special leave petitions did not survive.</description>
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